Mastermind Tutorials Private Limited, a company incorporated and registered under the provisions of the erstwhile The Companies Act, 1956, having its registered office at 51, Sampat Hills, Bicholi Mardana, Bypass Road, Indore - 452016, Madhya Pradesh India (“Mastermind”, “we,” “us” or “our”) is committed to protecting and respecting your privacy. This privacy policy (“Privacy Policy”) explains how we collect, use, share and protect data that identifies or is associated with you (“personal data”) in relation to our website www.mastermindabacus.com including the services offered on such website (the “Platform”), and your choices about the collection and use of your information  and it shall be read with the Terms and Conditions given on (URL:https://mastermindabacus.com/terms-conditions) and the COPPA Direct Notice to Parents. 

In this agreement the terms “you”, “your” “yours” & “you and/or your child “refer to You (as the User of the Platform).It also include all the persons who are applying or selected to teach on the platform (“Trainer(s)”).Any person below 18 years can  register on our website only with consent/help of his/her parent or legal guardian.

 By choosing to visit and/or avail any Services provided by us, you are  providing your consent to this Privacy Policy and accepting the Terms of Use, you agree to the collection, use and transfer of your Personal Information as set out in this Privacy Policy  (as may be amended from time to time). If you do not agree with the terms of this Privacy Policy, please do not use/access this Website.   

Before accessing or using the Platform, please ensure that you have read and understood our Privacy Policy.

1. Why we collect your personal data  : a. you have given us consent  b. processing is necessary to provide our services to you and your child  c. managing our business and relationship with you   d. understanding and responding to inquiries and User feedback   e. understanding how our Users use the Platform  f. improving our Platform and offerings;

2. How we process your data: We are committed to protecting the privacy of children and others who use our sites or services. We are very serious about the way we process data about our users, including parents, students, trainers and others, we comply with amongst others the  EU GDPR (General Data Protection Regulation) and the COPPA Children's Online Privacy Protection Act, which are now becoming global accepted standards. This Privacy Policy covers our data collection and privacy practices and describes your rights to access, correct, or restrict our use of your personal data. 

3.Types of data we collect

A. The data listed below is stored by us and is associated with your account.

Demographic & Identity data of the child

Name, Parent or guardian name, email address, contact number, photograph, location, gender, school name, birth date and year of the child

Demographic, Identity and financial data  of the Trainer or other user

Name, email address, contact number, photograph, location, gender,  personal biographical and academic accreditation, professional qualifications, work history, in addition to location and residency status, PAN and tax status and financial data (e.g., bank account, wallet, or other payment details)

Shared Content

While using our Services we allow you to interact with trainers/ mentors,other students, counsellors, and other users or share content publicly, including in class performance, assignments and by allowing you to post reviews sharing in class experiences including performance updates. Such shared content may be publicly viewable by others depending on where it is posted.

Class Content

We record the classes/demo classes’ conversation or take screenshots during the classes. We reserve all the rights and ownership on such recordings and screenshots.

Payment Data

If you make payment, we collect certain data about your payment (such as your name pin/zip/geography code, currency, and payment instrument) as necessary to process your order.

You must provide certain payment and billing data directly to our payment processing partners, including your name, payment instrument information such as debit/credit card information, payment provider login, billing address, and geo/pin/zip code. For security, we do not collect or store sensitive cardholder data, such as full debit/credit card numbers or card authentication data.

Publicly available sources

We may also receive Personal Data about you from publicly available sources of information.



B    We collect Your Data in Automated Manner, when you access the Services 

Online Identifiers and other technical Data

 IP address, transaction logs, device details, operating system type and version, browser type and version, unique device identifiers, domain and other systems data, and platform types (“System Data”).

Usage Data

content accessed, courses accessed on our platform, demo classes and sessions, events participation and performance statistics, time spent on games, worksheets, apps or web pages, or other parts of the Service, pages visited, features used such as games played, content downloaded, your click data including search queries, date and time.

Geographic Data

An approximate geographic location, including information like country, city, time zone, and geographic coordinates, calculated based on your IP address.


4. How we obtain your Personal Data?

When you inquire or register for our services you provide your personal data to us and some data might be collected in an automated manner when you navigate through the platform as mentioned in clause 3, and it may also include the information collected through cookies, web beacons and other tracking technologies.  We do not collect Personal Data from children for the purposes of behavioral advertising.

5. How do we use your Personal Data?

We use your data to provide our Services, communicate with you, verify your identity, troubleshoot issues, improve and update our Services, analyze how people use our Services, serve personalized advertising, and as required by law or necessary for safety and integrity. We also use your data to send you information about our other products or services which may be of interest to you (you may always opt out of such communications by clicking an “Unsubscribe” link in the footer of each email), to furnish your information to service partners and providers only to the extent necessary for delivering the relevant services.

Any portion of the Information containing personal data relating to minors provided by you shall be deemed to be given with the consent of the minor's legal guardian. Such consent is deemed to be provided by your registration with us.

6. How, when do we share your Personal Data with third parties?

We share certain data about you with our instructors (Teachers), our business partners, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

With Service Providers, Contractors, and Analytics : We share your data with third-party companies who perform services on our behalf, like payment processing, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.

With Your Instructors: We share data like your Name,city, country, and your activities, your performance, attendance / grade and gender details, fee status, validity details with your teacher

With Other Students: Your shared content and performance may also be publicly viewable by other users on the platform.

For Security and Legal Compliance: we can share the required information to the law enforcement authorities, government authorities, courts, dispute resolution bodies, regulators, auditors and any party appointed or requested by applicable regulators to carry out investigations or audits of our activities

For information on how we disclose Personal Data collected from US child users, see COPPA Direct Notice to Parents

7. How do we secure your and your child's Personal Data?

We are committed to protecting your data.  Processing your Personal Information will be done only in an authorized manner and subject to a duty of confidentiality. We will notify you about any applicable regulator of a suspected data security breach where we are legally required to do so.   

Notwithstanding anything contained anywhere in this Policy; we cannot assure absolute security to your Personal Information and by entering or by logging into our Website, you explicitly agree not to sue us for any data breach.

8. How long do we keep your and your child's Personal Data?

We generally keep your information only as long as needed to provide the services on our Platform. We will retain your information as necessary to comply with legal, accounting, or regulatory requirements.

We may take reasonable steps to delete or permanently de-identify your Personal Data that is no longer needed. We will delete your personal information in accordance with applicable laws and no later than 3 (three) years from when we no longer require it for offering our services to you.  We shall not sell any Personal Data of yours and/ or the children for the purpose of marketing, advertising, or any other third-party use, except in accordance with express consent obtained from you.

9. Links to other Websites

Our website may contain links to websites of other organizations. This privacy notice does not cover how those organizations process your Personal Data. We encourage you to read the privacy notices on the other websites you visit.

10. Your Rights

You have certain rights around the use of your data, including the ability to opt out of promotional SMS / emails, cookies, and collection of your data by certain analytics providers. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data. Parents who believe we have unintentionally collected personal data about their underage child should contact us for help in deleting that information.

You may enjoy following rights regarding your personal data we process to serve you depending on the jurisdiction in which you are resident.

  • Access: You have a right to know what personal data we hold about you and to obtain a copy.

  • Withdraw your consent: You have a right to withdraw your consent to process your and your child’s personal data

  • Data portability: Subject to law, you have a right to obtain in machine readable format the personal data you have provided to us.

  • Rectification and erasure: You have a right to have incomplete, incorrect, unnecessary or outdated personal data about you deleted or updated. If any of your details change or if you believe that any Personal Data we have collected about you is inaccurate, you can contact us at info@mmtpl.com and we will take all reasonable steps to correct it.

  • The right to object. You have the right to object to our processing of your Personal Data.

  • The right of restriction. You have the right to request that we restrict the processing of your Personal Data.

You may exercise your rights by managing your Participant Account and choices through our products and services or, if that is not possible, by contacting us. In some cases, if you withdraw your consent or want us to delete or stop processing your personal data, we may not be able to provide the services to you post deletion of the data.

If you are not satisfied with what we provide when you exercise your rights, you can let us know by contacting us.

11. US Child Users

If your child is located in the United States of America, we handle their Personal Data in compliance with the Children's Online Privacy Protection Act (“COPPA”). COPPA applies to child users who are under the age of 13.

COPPA requires that we receive verifiable parental consent from the child's parent or legal guardian before the collection, use, or disclosure of the child's Personal Data. To learn more about how we receive this parental consent, what personal data we collect from children, how we use this data, including when we disclose it, go to COPPA Direct Notice to Parents. We display this notice to all parents and guardians when soliciting and obtaining verifiable parental consent.

If you are a parent or guardian and you believe that your child has provided us with Personal Data without your consent, please contact us as at info@mmtpl.com we will dispose of that data in accordance with applicable laws and regulations.

Parents can always refuse to permit us to collect further Personal Data, request to review their child's Personal Data, or request that we delete from our records the personal data collected from or about their child. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service, as the nature of our services requires collection of Personal Data. To exercise any of these options, please contact us at info@mmtpl.com Please be aware that to protect children’s privacy and security, we will take reasonable steps to verify a parent or legal guardian’s identity before granting access to any personal data.

12. EU Child Users

If your child is a resident of a Member State of the European Union, we will treat their Personal Data as a child’s Personal Data if they are under 16 years of age, and receive consent of the holder of parental responsibility as required for the processing of Personal Data. All residents of the European Union further have certain specific rights granted by the General Data Protection Regulation (“EU-GDPR”). See Annexure A to this privacy policy.

13. UK Child Users

If your child is a resident of the United Kingdom, we will treat their Personal Data as a child’s Personal Data if they are under 13 years of age, and receive consent of the holder of parental responsibility as required for the processing of Personal Data. All residents of the United Kingdom further have certain specific rights granted by the General Data Protection Regulation (“UK-GDPR”) and Data Protection Act, 2018 (“DPA”). See Annexure B to this privacy policy.

14. Contact Information

We can be reached, for all questions and directions related to this privacy policy (the “Privacy Policy”), by: Sending an email to info@mmtpl.com  or Sending a letter marked to the attention of Privacy Policy C/O Nodal Officer,  Mastermind Tutorials Pvt. Ltd. 51 Sampat Hills, Bicholi Mardana By Pass Indore MP India.

15.Changes to this Policy

We may modify or update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

ANNEXURE A

The below additional rights are available to you if you are an EU resident:

1. Right of Access

Upon request, you have the right to get confirmation as to whether or not We are processing Your Personal Data, a copy of Your Personal Data and any other additional information as specified by EU-GDPR.

2. Right to Rectification

Upon request, you have the right to get your inaccurate Personal Data rectified and you’re incomplete Personal Data completed.

3. Right to Erasure

Upon request, you have the right to obtain erasure or deletion of Your Personal Data on the grounds specified by EU-GDPR unless there is any exception specified by EU-GDPR that is preventing us to execute your right.

4. Right to Restriction of Processing

Upon request, you have the right to request restriction of processing of Your Personal Data on the grounds specified by EU-GDPR.

5. Right to Data Portability

Upon request, you have right to receive and/or transmittal to any other organization, Your Personal Data that you have provided to us in a structured, commonly used and machine- readable format on the grounds specified by EU-GDPR unless there is any exception specified by EU-GDPR is preventing us to execute your right.

6. Right to Object

Upon request, you have the right to object to the processing of Your Personal Data on the grounds specified by EU-GDPR.

7. Right to not be subject to automated decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning you.

8. Right to lodge a complaint with the Supervisory Authority

You have the right to lodge a complaint with a supervisory authority, specifically in the Member State of Your habitual residence, place of work or place of an alleged infringement of the General Data Protection Regulation.

ANNEXURE B

The below additional rights are available to you if you are a UK resident:

1. Right of Access

Upon request, you have the right to get confirmation as to whether or not We are processing Your Personal Data, a copy of Your Personal Data and any other additional information as specified by UK-GDPR.

2. Right to Rectification

Upon request, you have the right to get your inaccurate Personal Data rectified and your incomplete Personal Data completed.

3. Right to Erasure

Upon request, you have the right to obtain erasure or deletion of Your Personal Data on the grounds specified by UK-GDPR unless there is any exception specified by UK-GDPR and/or DPA that is preventing us to execute your right.

4. Right to Restriction of Processing

Upon request, you have the right to request restriction of processing of Your Personal Data on the grounds specified by UK-GDPR.

5. Right to Data Portability

Upon request, you have right to receive and/or transmittal to any other organization, Your Personal Data that you have provided to us in a structured, commonly used and machine- readable format on the grounds specified by UK-GDPR unless there is any exception specified by UK-GDPR and/or DPA preventing us to execute your right.

6. Right to Object

Upon request, you have the right to object to the processing of Your Personal Data on the grounds specified by UK-GDPR.

7. Right to not be subject to automated decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning you.

8. Right to lodge a complaint with the Supervisory Authority

You have the right to lodge a complaint with the UK Information Commissioner’s Office in relation to an alleged infringement of UK data protection law.